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COMMONWEALTH OF MASSACHUSETTS
WORCESTER, SS. SUPERIOR COURT
CIVIL ACTION NO.:
VINCENT D’AMBRA,
LISA D’AMBRA, Individually and as parent
and next friend of minor children:
MORGAN D’AMBRA, CHARLOTTE D’AMBRA
LUCY D’AMBRA, & VINCENT D’AMBRA, JR.
Plaintiffs
v.
DP23 BULLDOGS, LLC and
DANIEL PLOURDE,
Defendants.
COMPLAINT & JURY DEMAND
PARTIES
1. At all times relevant to this Complaint, Plaintiff, Vincent D’Ambra, was legally married to
Lisa D’Ambra and was a resident of the Commonwealth of Massachusetts and currently resides
at a long term care facility as a result of the injuries sustained in this incident.
2. At all times relevant to this Complaint, Plaintiff, Lisa D’Ambra, wife of Vincent D’Ambra,
and their four (4) minor children: Morgan D’Ambra, Charlotte D’Ambra, Lucy D’Ambra, and
Vincent D’Ambra, Jr., were residents of the Commonwealth of Massachusetts, and currently
resides at 15 Robin Way, Meredith, NH.
3. Defendant, DP23 BULLDOGS, LLC, is a Massachusetts corporation. At all times relevant to
this Complaint the Defendant was doing business within the Commonwealth of Massachusetts,
with a principal place of business and registered agent, Daniel Plourde, located in Worcester
County at 5 Quaboag Street, Brookfield, Massachusetts.
4. Defendant, Daniel Plourde, is the manager and sole member of DP23 BULLDOGS, LLC’s
corporate management. Defendant Plourde is the owner, operator, proprietor, manager,
supervisor, and designer of MX23 Brookfield, a motocross track owned by Defendant Plourde
through his corporation, DP23 BULLDOGS LLC. MX23 Brookfield is located in Worcester
County at 5 Quaboag Street, Brookfield, Massachusetts.
FACTS
5. The forgoing paragraphs are hereby re-alleged and incorporated by reference as if set forth
fully herein.
6. On or about September 9, 2018, MX23 Brookfield, was owned by Defendants, DP23
BULLDOGS, LLC, (“DP23”) and Daniel Plourde (“Plourde”).
7. On or about September 9, 2018, Defendant Plourde was the owner, operator, proprietor,
manager, supervisor, and designer of MX23 Brookfield, located 5 Quaboag Street, Brookfield,
Massachusetts (“Subject Premises”)
8. On or about September 9, 2018, while lawfully on the Subject Premises, Plaintiff Vincent
D’Ambra, was seriously and permanently injured and disabled as a result of the negligence of
the Defendants. As a result of the Defendant’s negligence, Plaintiff Vincent D’Ambra was
caused to suffer serious and permanent personal injuries and damages as set forth below when
was caused to fall as a result of Defendants’ negligent and unreasonably dangerous design and
operation of MX23 Brookfield.
9. Defendants failed to exercise due care in designing, maintaining, supervising, and operating
the Subject Premises. Defendants designed, maintained, and operated MX23 in a grossly
negligent manner with a willful and wonton disregard for the safety of their patrons.
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COUNT I – NEGLIGENCE
VINCENT D’AMBRA V. DP23 BULLDOGS, LLC
11. The forgoing paragraphs are hereby re-alleged and incorporated by reference as if set forth
fully herein.
12. Now comes the Plaintiff, Vincent D’Ambra, in the above-entitled matter and states that on or
about September 9, 2018, he was lawfully on the Subject Premises, which was owned by
Defendant DP23 BULLDOGS, LLC.
13. On or about September 9, 2018, Defendant DP23 owed Plaintiff a duty of care including but
not limited to, operating, supervising, maintaining, inspecting, and/or designing, MX23 in a
reasonably safe condition.
14. Defendant DP23 had exclusive control of the area where the Plaintiff fell and suffered injuries.
Defendant breached its duty of operating, supervising, maintaining, inspecting, and/or
designing, MX23 in a reasonably safe condition.
15. As a direct result of the Defendant’s negligence in failing to properly design, inspect, repair,
warn, supervise, and/or maintain the Subject Premises in a reasonably safe condition, the
Plaintiff was seriously and permanently injured.
16. The Defendant knew or should have known of the unreasonable danger and risk presented to
patrons in the area where Plaintiff sustained injuries on the Subject Premises.
17. The aforementioned incident was caused solely and exclusively by reason of the negligence of
the Defendant, individually and/or through agents, servants, or employees, and was caused in
no manner whatsoever by any act or failure to act on the part of the Plaintiff.
18. As a direct and proximate result of the negligence of the defendant, its agent(s), servant(s)
and/or employee(s) as described above, the Plaintiff has suffered serious and permanently
disabling personal injuries including but not limited to hyperextension injury and multiple
fractures to the cervical spine resulting in immediate paralysis, head injury, and other serious
and diverse personal injuries, some, or all of which may be permanent in nature.
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19. As a further result of the negligence of the Defendant, the Plaintiff is now confined to a long-
term care facility and has been put to great expense for medical treatment and out of pocket
costs and will for an indefinite time in the future be obliged to expend further monies in an
effort to cure himself of the injuries he suffered, all to his great detriment and loss.
20. As a further result of the negligence of the Defendant, the Plaintiff has undergone great
physical pain and suffering as well as mental anguish and will continue to suffer both physical
and mental pain and suffering in the future, all to his great detriment and loss.
21. In addition to all claims of damages recognized by law, Vincent D’Ambra also claims
exemplary damages and punitive damages as applicable against the Defendant.
WHEREFORE, Plaintiff demands Judgment against the Defendant in an amount determined
to be fair and just by this Honorable Court, together with such other damages as the Court deems
just and appropriate, together with interest, costs, and attorney’s fees, as appropriate.
COUNT II – NEGLIGENCE
VINCENT D’AMBRA V. DANIEL PLOURDE
22. The forgoing paragraphs are hereby re-alleged and incorporated by reference as if set forth
fully herein.
23. Now comes the Plaintiff, Vincent D’Ambra, in the above-entitled matter and states that on or
about September 9, 2018, he was lawfully on the Subject Premises, which was owned,
operated, managed, designed, and/or controlled by Defendant Plourde.
24. Oor about September 9, 2018, Defendant Plourde owed Plaintiff a duty of care including but
not limited to, operating, supervising, maintaining, inspecting, and/or designing, MX23 in a
reasonably safe condition.
25. Defendant Plourde had exclusive control of the area where the Plaintiff fell and suffered
injuries. Defendant breached its duty of operating, supervising, maintaining, inspecting, and/or
designing, MX23 in a reasonably safe condition.
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26. As a direct result of the Defendant’s negligence in failing to properly design, inspect, repair,
warn, supervise, and/or maintain the Subject Premises in a reasonably safe condition, the
Plaintiff was seriously and permanently injured.
27. The Defendant knew or should have known of the unreasonable danger and risk presented to
patrons in the area where Plaintiff sustained injuries on the Subject Premises.
28. The aforementioned incident was caused solely and exclusively by reason of the negligence of
the Defendant, individually and/or through agents, servants, or employees, and was caused in
no manner whatsoever by any act or failure to act on the part of the Plaintiff.
29. As a direct and proximate result of the negligence of the defendant, its agent(s), servant(s)
and/or employee(s) as described above, the Plaintiff has suffered serious and permanently
disabling personal injuries including but not limited to hyperextension injury and multiple
fractures to the cervical spine resulting in immediate paralysis, head injury, and other serious
and diverse personal injuries, some, or all of which may be permanent in nature.
30. As a further result of the negligence of the Defendant, the Plaintiff is now confined to a long-
term care facility and has been put to great expense for medical treatment and out of pocket
costs and will for an indefinite time in the future be obliged to expend further monies in an
effort to cure himself of the injuries he suffered, all to his great detriment and loss.
31. As a further result of the negligence of the Defendant, the Plaintiff has undergone great
physical pain and suffering as well as mental anguish and will continue to suffer both physical
and mental pain and suffering in the future, all to his great detriment and loss.
32. In addition to all claims of damages recognized by law, Vincent D’Ambra also claims
exemplary damages and punitive damages as applicable against the Defendant.
WHEREFORE, Plaintiff demands Judgment against the Defendant in an amount determined
to be fair and just by this Honorable Court, together with such other damages as the Court deems
just and appropriate, together with interest, costs, and attorney’s fees, as appropriate.
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COUNT III – SPOUSAL LOSS OF CONSORTIUM
LISA D’AMBRA V. DP23 BULLDOGS, LLC & DANIEL PLOURDE
34. The forgoing paragraphs are hereby re-alleged and incorporated by reference as if set forth
fully herein.
35. On or about September 9, 2018, Lisa D’Ambra was legally married to Vincent D’Ambra.
36. Prior to September 9, 2018, Plaintiff, Lisa D’Ambra, derived all of the usual benefits of
marriage from her husband and Co-Plaintiff, Vincent D’Ambra, including but not limited to,
comfort, aid, society, affection, companionship, assistance, enjoyment, and financial and
emotional support.
37. As a direct and proximate cause of the negligence of the Defendants, Plaintiff Vincent
D’Ambra was caused to sustain serious and permanent injuries as set forth above.
38. As a direct and proximate result of the negligence of the Defendants, Lisa D’Ambra has been
and will be deprived in the future of the comfort, aid, society, affection, companionship,
assistance, enjoyment, and financial support, of her husband, Plaintiff Vincent D’Ambra,
which she ought to have had and would have had, but for the Defendants’ negligence and
carelessness, and that the Plaintiff thereby suffered great, financial hardship, mental and
emotional anguish and distress, and will continue in the future, all to her great detriment and
loss.
39. In addition to all claims of damages recognized by law, Lisa D’Ambra also claims exemplary
damages and punitive damages as applicable against all Defendants.
WHEREFORE, Plaintiff demands Judgment against the Defendant in an amount determined
to be fair and just by this Honorable Court, together with such other damages as the Court deems
just and appropriate, together with interest, costs, and attorney’s fees, as appropriate.
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COUNT IV –LOSS OF PARENTAL CONSORTIUM
LISA D’AMBRA as parent and next friend of minor MORGAN D’AMBRA
V. DP23 BULLDOGS, LLC & DANIEL PLOURDE
40. The forgoing paragraphs are hereby re-alleged and incorporated by reference as if set forth
fully herein.
41. As set forth above, Morgan D’Ambra was, at all relevant times, the minor child of Plaintiffs
Lisa and Vincent D’Ambra, and was emotionally and finically dependent on her parents.
42. As a direct and proximate cause of the negligence of the Defendants, Plaintiff Vincent
D’Ambra was caused to sustain serious and permanent injuries as set forth above.
43. As a direct and proximate result of the negligence of the Defendants, Morgan D’Ambra has
been and will be deprived in the future of the comfort, aid, guidance, advice, support,
companionship, and financial and emotional support of her father, Vincent D’Ambra.
44. As a direct and proximate result of the negligence of the Defendants, Morgan D’Ambra has
suffered financial hardship, mental and emotional anguish, and distress, as a result of the
serious and permanent injuries suffered by her father, Vincent D’Ambra, all to her great
detriment and loss.
45. In addition to all claims of damages recognized by law, Morgan D’Ambra also claims
exemplary damages and punitive damages as applicable against all Defendants.
WHEREFORE, Plaintiff demands Judgment against the Defendant in an amount determined
to be fair and just by this Honorable Court, together with such other damages as the Court deems
just and appropriate, together with interest, costs, and attorney’s fees, as appropriate.
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COUNT V –LOSS OF PARENTAL CONSORTIUM
LISA D’AMBRA as parent and next friend of minor CHARLOTTE D’AMBRA
V. DP23 BULLDOGS, LLC & DANIEL PLOURDE
46. The forgoing paragraphs are hereby re-alleged and incorporated by reference as if set forth
fully herein.
47. As set forth above, Charlotte D’Ambra was, at all relevant times, the minor child of Plaintiffs
Lisa and Vincent D’Ambra, and was emotionally and finically dependent on her parents.
48. As a direct and proximate cause of the negligence of the Defendants, Plaintiff Vincent
D’Ambra was caused to sustain serious and permanent injuries as set forth above.
49. As a direct and proximate result of the negligence of the Defendants, Charlotte D’Ambra has
been and will be deprived in the future of the comfort, aid, guidance, advice, support,
companionship, and financial and emotional support of her father, Vincent D’Ambra.
50. As a direct and proximate result of the negligence of the Defendants, Charlotte D’Ambra has
suffered financial hardship, mental and emotional anguish, and distress, as a result of the
serious and permanent injuries suffered by her father, Vincent D’Ambra, all to her great
detriment and loss.
51. In addition to all claims of damages recognized by law, Charlotte D’Ambra also claims
exemplary damages and punitive damages as applicable against all Defendants.
WHEREFORE, Plaintiff demands Judgment against the Defendant in an amount determined
to be fair and just by this Honorable Court, together with such other damages as the Court deems
just and appropriate, together with interest, costs, and attorney’s fees, as appropriate.
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COUNT VI –LOSS OF PARENTAL CONSORTIUM
LISA D’AMBRA as parent and next friend of minor LUCY D’AMBRA
V. DP23 BULLDOGS, LLC & DANIEL PLOURDE
52. The forgoing paragraphs are hereby re-alleged and incorporated by reference as if set forth
fully herein.
53. As set forth above, Lucy D’Ambra was, at all relevant times, the minor child of Plaintiffs Lisa
and Vincent D’Ambra, and was emotionally and finically dependent on her parents.
54. As a direct and proximate cause of the negligence of the Defendants, Plaintiff Vincent
D’Ambra was caused to sustain serious and permanent injuries as set forth above.
55. As a direct and proximate result of the negligence of the Defendants, Lucy D’Ambra has been
and will be deprived in the future of the comfort, aid, guidance, advice, support,
companionship, and financial and emotional support of her father, Vincent D’Ambra.
56. As a direct and proximate result of the negligence of the Defendants, Lucy D’Ambra has
suffered financial hardship, mental and emotional anguish, and distress, as a result of the
serious and permanent injuries suffered by her father, Vincent D’Ambra, all to her great
detriment and loss.
57. In addition to all claims of damages recognized by law, Lucy D’Ambra also claims exemplary
damages and punitive damages as applicable against all Defendants.
WHEREFORE, Plaintiff demands Judgment against the Defendant in an amount determined
to be fair and just by this Honorable Court, together with such other damages as the Court deems
just and appropriate, together with interest, costs, and attorney’s fees, as appropriate.
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COUNT VII –LOSS OF PARENTAL CONSORTIUM
LISA D’AMBRA as parent and next friend of minor VINCENT D’AMBRA JR.,
V. DP23 BULLDOGS, LLC & DANIEL PLOURDE
58. The forgoing paragraphs are hereby re-alleged and incorporated by reference as if set forth
fully herein.
59. As set forth above, Vincent D’Ambra, Jr., was, at all relevant times, the minor child of
Plaintiffs Lisa and Vincent D’Ambra, and was emotionally and finically dependent on her
parents.
60. As a direct and proximate cause of the negligence of the Defendants, Plaintiff Vincent
D’Ambra was caused to sustain serious and permanent injuries as set forth above.
61. As a direct and proximate result of the negligence of the Defendants, Vincent D’Ambra, Jr.,
has been and will be deprived in the future of the comfort, aid, guidance, advice, support,
companionship, and financial and emotional support of his father, Vincent D’Ambra.
62. As a direct and proximate result of the negligence of the Defendants, Vincent D’Ambra, Jr.,
has suffered financial hardship, mental and emotional anguish, and distress, as a result of the
serious and permanent injuries suffered by his father, Vincent D’Ambra, all to his great
detriment and loss.
63. In addition to all claims of damages recognized by law, Vincent D’Ambra, Jr.,also claims
exemplary damages and punitive damages as applicable against all Defendants.
WHEREFORE, Plaintiff demands Judgment against the Defendant in an amount determined
to be fair and just by this Honorable Court, together with such other damages as the Court deems
just and appropriate, together with interest, costs, and attorney’s fees, as appropriate.
PLAINTIFFS HEREBY DEMAND A JURY TRIAL ON ALL COUNTS
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Respectfully Submitted,
The Plaintiffs
By their attorneys,
Kelsey Raycroft Rose, BBO # 692102
MORGAN & MORGAN, P.A.
One State Street, Suite 750
Boston, MA 02109
KRaycroftRose@forthepeople.com
Date: 08/31/21 (857) 383-4928
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COMMONWEALTH OF MASSACHUSETTS WORCESTER, SS. SUPERIOR COURT CIVIL ACTION NO.: VINCENT D’AMBRA, LISA D’AMBRA, Individually and as parent and next friend of minor children: MORGAN D’AMBRA, CHARLOTTE D’AMBRA LUCY D’AMBRA, & VINCENT D’AMBRA, JR. Plaintiffs v. DP23 BULLDOGS, LLC and DANIEL PLOURDE, Defendants. COMPLAINT & JURY DEMAND PARTIES 1. At all times relevant to this Complaint, Plaintiff, Vincent D’Ambra, was legally married to Lisa D’Ambra and was a resident of the Commonwealth of Massachusetts and currently resides at a long term care facility as a result of the injuries sustained in this incident. 2. At all times relevant to this Complaint, Plaintiff, Lisa D’Ambra, wife of Vincent D’Ambra, and their four (4) minor children: Morgan D’Ambra, Charlotte D’Ambra, Lucy D’Ambra, and Vincent D’Ambra, Jr., were residents of the Commonwealth of Massachusetts, and currently resides at 15 Robin Way, Meredith, NH. 3. Defendant, DP23 BULLDOGS, LLC, is a Massachusetts corporation. At all times relevant to this Complaint the Defendant was doing business within the Commonwealth of Massachusetts, with a principal place of business and registered agent, Daniel Plourde, located in Worcester County at 5 Quaboag Street, Brookfield, Massachusetts. 4. Defendant, Daniel Plourde, is the manager and sole member of DP23 BULLDOGS, LLC’s corporate management. Defendant Plourde is the owner, operator, proprietor, manager, supervisor, and designer of MX23 Brookfield, a motocross track owned by Defendant Plourde through his corporation, DP23 BULLDOGS LLC. MX23 Brookfield is located in Worcester County at 5 Quaboag Street, Brookfield, Massachusetts. FACTS 5. The forgoing paragraphs are hereby re-alleged and incorporated by reference as if set forth fully herein. 6. On or about September 9, 2018, MX23 Brookfield, was owned by Defendants, DP23 BULLDOGS, LLC, (“DP23”) and Daniel Plourde (“Plourde”). 7. On or about September 9, 2018, Defendant Plourde was the owner, operator, proprietor, manager, supervisor, and designer of MX23 Brookfield, located 5 Quaboag Street, Brookfield, Massachusetts (“Subject Premises”) 8. On or about September 9, 2018, while lawfully on the Subject Premises, Plaintiff Vincent D’Ambra, was seriously and permanently injured and disabled as a result of the negligence of the Defendants. As a result of the Defendant’s negligence, Plaintiff Vincent D’Ambra was caused to suffer serious and permanent personal injuries and damages as set forth below when was caused to fall as a result of Defendants’ negligent and unreasonably dangerous design and operation of MX23 Brookfield. 9. Defendants failed to exercise due care in designing, maintaining, supervising, and operating the Subject Premises. Defendants designed, maintained, and operated MX23 in a grossly negligent manner with a willful and wonton disregard for the safety of their patrons. 2 COUNT I – NEGLIGENCE VINCENT D’AMBRA V. DP23 BULLDOGS, LLC 11. The forgoing paragraphs are hereby re-alleged and incorporated by reference as if set forth fully herein. 12. Now comes the Plaintiff, Vincent D’Ambra, in the above-entitled matter and states that on or about September 9, 2018, he was lawfully on the Subject Premises, which was owned by Defendant DP23 BULLDOGS, LLC. 13. On or about September 9, 2018, Defendant DP23 owed Plaintiff a duty of care including but not limited to, operating, supervising, maintaining, inspecting, and/or designing, MX23 in a reasonably safe condition. 14. Defendant DP23 had exclusive control of the area where the Plaintiff fell and suffered injuries. Defendant breached its duty of operating, supervising, maintaining, inspecting, and/or designing, MX23 in a reasonably safe condition. 15. As a direct result of the Defendant’s negligence in failing to properly design, inspect, repair, warn, supervise, and/or maintain the Subject Premises in a reasonably safe condition, the Plaintiff was seriously and permanently injured. 16. The Defendant knew or should have known of the unreasonable danger and risk presented to patrons in the area where Plaintiff sustained injuries on the Subject Premises. 17. The aforementioned incident was caused solely and exclusively by reason of the negligence of the Defendant, individually and/or through agents, servants, or employees, and was caused in no manner whatsoever by any act or failure to act on the part of the Plaintiff. 18. As a direct and proximate result of the negligence of the defendant, its agent(s), servant(s) and/or employee(s) as described above, the Plaintiff has suffered serious and permanently disabling personal injuries including but not limited to hyperextension injury and multiple fractures to the cervical spine resulting in immediate paralysis, head injury, and other serious and diverse personal injuries, some, or all of which may be permanent in nature. 3 19. As a further result of the negligence of the Defendant, the Plaintiff is now confined to a long- term care facility and has been put to great expense for medical treatment and out of pocket costs and will for an indefinite time in the future be obliged to expend further monies in an effort to cure himself of the injuries he suffered, all to his great detriment and loss. 20. As a further result of the negligence of the Defendant, the Plaintiff has undergone great physical pain and suffering as well as mental anguish and will continue to suffer both physical and mental pain and suffering in the future, all to his great detriment and loss. 21. In addition to all claims of damages recognized by law, Vincent D’Ambra also claims exemplary damages and punitive damages as applicable against the Defendant. WHEREFORE, Plaintiff demands Judgment against the Defendant in an amount determined to be fair and just by this Honorable Court, together with such other damages as the Court deems just and appropriate, together with interest, costs, and attorney’s fees, as appropriate. COUNT II – NEGLIGENCE VINCENT D’AMBRA V. DANIEL PLOURDE 22. The forgoing paragraphs are hereby re-alleged and incorporated by reference as if set forth fully herein. 23. Now comes the Plaintiff, Vincent D’Ambra, in the above-entitled matter and states that on or about September 9, 2018, he was lawfully on the Subject Premises, which was owned, operated, managed, designed, and/or controlled by Defendant Plourde. 24. Oor about September 9, 2018, Defendant Plourde owed Plaintiff a duty of care including but not limited to, operating, supervising, maintaining, inspecting, and/or designing, MX23 in a reasonably safe condition. 25. Defendant Plourde had exclusive control of the area where the Plaintiff fell and suffered injuries. Defendant breached its duty of operating, supervising, maintaining, inspecting, and/or designing, MX23 in a reasonably safe condition. 4 26. As a direct result of the Defendant’s negligence in failing to properly design, inspect, repair, warn, supervise, and/or maintain the Subject Premises in a reasonably safe condition, the Plaintiff was seriously and permanently injured. 27. The Defendant knew or should have known of the unreasonable danger and risk presented to patrons in the area where Plaintiff sustained injuries on the Subject Premises. 28. The aforementioned incident was caused solely and exclusively by reason of the negligence of the Defendant, individually and/or through agents, servants, or employees, and was caused in no manner whatsoever by any act or failure to act on the part of the Plaintiff. 29. As a direct and proximate result of the negligence of the defendant, its agent(s), servant(s) and/or employee(s) as described above, the Plaintiff has suffered serious and permanently disabling personal injuries including but not limited to hyperextension injury and multiple fractures to the cervical spine resulting in immediate paralysis, head injury, and other serious and diverse personal injuries, some, or all of which may be permanent in nature. 30. As a further result of the negligence of the Defendant, the Plaintiff is now confined to a long- term care facility and has been put to great expense for medical treatment and out of pocket costs and will for an indefinite time in the future be obliged to expend further monies in an effort to cure himself of the injuries he suffered, all to his great detriment and loss. 31. As a further result of the negligence of the Defendant, the Plaintiff has undergone great physical pain and suffering as well as mental anguish and will continue to suffer both physical and mental pain and suffering in the future, all to his great detriment and loss. 32. In addition to all claims of damages recognized by law, Vincent D’Ambra also claims exemplary damages and punitive damages as applicable against the Defendant. WHEREFORE, Plaintiff demands Judgment against the Defendant in an amount determined to be fair and just by this Honorable Court, together with such other damages as the Court deems just and appropriate, together with interest, costs, and attorney’s fees, as appropriate. 5 COUNT III – SPOUSAL LOSS OF CONSORTIUM LISA D’AMBRA V. DP23 BULLDOGS, LLC & DANIEL PLOURDE 34. The forgoing paragraphs are hereby re-alleged and incorporated by reference as if set forth fully herein. 35. On or about September 9, 2018, Lisa D’Ambra was legally married to Vincent D’Ambra. 36. Prior to September 9, 2018, Plaintiff, Lisa D’Ambra, derived all of the usual benefits of marriage from her husband and Co-Plaintiff, Vincent D’Ambra, including but not limited to, comfort, aid, society, affection, companionship, assistance, enjoyment, and financial and emotional support. 37. As a direct and proximate cause of the negligence of the Defendants, Plaintiff Vincent D’Ambra was caused to sustain serious and permanent injuries as set forth above. 38. As a direct and proximate result of the negligence of the Defendants, Lisa D’Ambra has been and will be deprived in the future of the comfort, aid, society, affection, companionship, assistance, enjoyment, and financial support, of her husband, Plaintiff Vincent D’Ambra, which she ought to have had and would have had, but for the Defendants’ negligence and carelessness, and that the Plaintiff thereby suffered great, financial hardship, mental and emotional anguish and distress, and will continue in the future, all to her great detriment and loss. 39. In addition to all claims of damages recognized by law, Lisa D’Ambra also claims exemplary damages and punitive damages as applicable against all Defendants. WHEREFORE, Plaintiff demands Judgment against the Defendant in an amount determined to be fair and just by this Honorable Court, together with such other damages as the Court deems just and appropriate, together with interest, costs, and attorney’s fees, as appropriate. 6 COUNT IV –LOSS OF PARENTAL CONSORTIUM LISA D’AMBRA as parent and next friend of minor MORGAN D’AMBRA V. DP23 BULLDOGS, LLC & DANIEL PLOURDE 40. The forgoing paragraphs are hereby re-alleged and incorporated by reference as if set forth fully herein. 41. As set forth above, Morgan D’Ambra was, at all relevant times, the minor child of Plaintiffs Lisa and Vincent D’Ambra, and was emotionally and finically dependent on her parents. 42. As a direct and proximate cause of the negligence of the Defendants, Plaintiff Vincent D’Ambra was caused to sustain serious and permanent injuries as set forth above. 43. As a direct and proximate result of the negligence of the Defendants, Morgan D’Ambra has been and will be deprived in the future of the comfort, aid, guidance, advice, support, companionship, and financial and emotional support of her father, Vincent D’Ambra. 44. As a direct and proximate result of the negligence of the Defendants, Morgan D’Ambra has suffered financial hardship, mental and emotional anguish, and distress, as a result of the serious and permanent injuries suffered by her father, Vincent D’Ambra, all to her great detriment and loss. 45. In addition to all claims of damages recognized by law, Morgan D’Ambra also claims exemplary damages and punitive damages as applicable against all Defendants. WHEREFORE, Plaintiff demands Judgment against the Defendant in an amount determined to be fair and just by this Honorable Court, together with such other damages as the Court deems just and appropriate, together with interest, costs, and attorney’s fees, as appropriate. 7 COUNT V –LOSS OF PARENTAL CONSORTIUM LISA D’AMBRA as parent and next friend of minor CHARLOTTE D’AMBRA V. DP23 BULLDOGS, LLC & DANIEL PLOURDE 46. The forgoing paragraphs are hereby re-alleged and incorporated by reference as if set forth fully herein. 47. As set forth above, Charlotte D’Ambra was, at all relevant times, the minor child of Plaintiffs Lisa and Vincent D’Ambra, and was emotionally and finically dependent on her parents. 48. As a direct and proximate cause of the negligence of the Defendants, Plaintiff Vincent D’Ambra was caused to sustain serious and permanent injuries as set forth above. 49. As a direct and proximate result of the negligence of the Defendants, Charlotte D’Ambra has been and will be deprived in the future of the comfort, aid, guidance, advice, support, companionship, and financial and emotional support of her father, Vincent D’Ambra. 50. As a direct and proximate result of the negligence of the Defendants, Charlotte D’Ambra has suffered financial hardship, mental and emotional anguish, and distress, as a result of the serious and permanent injuries suffered by her father, Vincent D’Ambra, all to her great detriment and loss. 51. In addition to all claims of damages recognized by law, Charlotte D’Ambra also claims exemplary damages and punitive damages as applicable against all Defendants. WHEREFORE, Plaintiff demands Judgment against the Defendant in an amount determined to be fair and just by this Honorable Court, together with such other damages as the Court deems just and appropriate, together with interest, costs, and attorney’s fees, as appropriate. 8 COUNT VI –LOSS OF PARENTAL CONSORTIUM LISA D’AMBRA as parent and next friend of minor LUCY D’AMBRA V. DP23 BULLDOGS, LLC & DANIEL PLOURDE 52. The forgoing paragraphs are hereby re-alleged and incorporated by reference as if set forth fully herein. 53. As set forth above, Lucy D’Ambra was, at all relevant times, the minor child of Plaintiffs Lisa and Vincent D’Ambra, and was emotionally and finically dependent on her parents. 54. As a direct and proximate cause of the negligence of the Defendants, Plaintiff Vincent D’Ambra was caused to sustain serious and permanent injuries as set forth above. 55. As a direct and proximate result of the negligence of the Defendants, Lucy D’Ambra has been and will be deprived in the future of the comfort, aid, guidance, advice, support, companionship, and financial and emotional support of her father, Vincent D’Ambra. 56. As a direct and proximate result of the negligence of the Defendants, Lucy D’Ambra has suffered financial hardship, mental and emotional anguish, and distress, as a result of the serious and permanent injuries suffered by her father, Vincent D’Ambra, all to her great detriment and loss. 57. In addition to all claims of damages recognized by law, Lucy D’Ambra also claims exemplary damages and punitive damages as applicable against all Defendants. WHEREFORE, Plaintiff demands Judgment against the Defendant in an amount determined to be fair and just by this Honorable Court, together with such other damages as the Court deems just and appropriate, together with interest, costs, and attorney’s fees, as appropriate. 9 COUNT VII –LOSS OF PARENTAL CONSORTIUM LISA D’AMBRA as parent and next friend of minor VINCENT D’AMBRA JR., V. DP23 BULLDOGS, LLC & DANIEL PLOURDE 58. The forgoing paragraphs are hereby re-alleged and incorporated by reference as if set forth fully herein. 59. As set forth above, Vincent D’Ambra, Jr., was, at all relevant times, the minor child of Plaintiffs Lisa and Vincent D’Ambra, and was emotionally and finically dependent on her parents. 60. As a direct and proximate cause of the negligence of the Defendants, Plaintiff Vincent D’Ambra was caused to sustain serious and permanent injuries as set forth above. 61. As a direct and proximate result of the negligence of the Defendants, Vincent D’Ambra, Jr., has been and will be deprived in the future of the comfort, aid, guidance, advice, support, companionship, and financial and emotional support of his father, Vincent D’Ambra. 62. As a direct and proximate result of the negligence of the Defendants, Vincent D’Ambra, Jr., has suffered financial hardship, mental and emotional anguish, and distress, as a result of the serious and permanent injuries suffered by his father, Vincent D’Ambra, all to his great detriment and loss. 63. In addition to all claims of damages recognized by law, Vincent D’Ambra, Jr.,also claims exemplary damages and punitive damages as applicable against all Defendants. WHEREFORE, Plaintiff demands Judgment against the Defendant in an amount determined to be fair and just by this Honorable Court, together with such other damages as the Court deems just and appropriate, together with interest, costs, and attorney’s fees, as appropriate. PLAINTIFFS HEREBY DEMAND A JURY TRIAL ON ALL COUNTS 10 Respectfully Submitted, The Plaintiffs By their attorneys, Kelsey Raycroft Rose, BBO # 692102 MORGAN & MORGAN, P.A. One State Street, Suite 750 Boston, MA 02109 KRaycroftRose@forthepeople.com Date: 08/31/21 (857) 383-4928 11